ML20076H658
| ML20076H658 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/31/1983 |
| From: | Durbin S CALIFORNIA, STATE OF |
| To: | PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML20076H654 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309060110 | |
| Download: ML20076H658 (14) | |
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UNITED 8MMB. OF AMERICA 00CKETED USMC NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY [AND . LICENSING APPEAL BOARD '83 SEP -2 A10 :29
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rfr"? r7 $EC". 'c In the Matter of =) p' " ' ~ ',c r -,1:L
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PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50 -32 3 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
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ANSWERS OF GOVERNOR DEUKMEJIAN TO APPLICANT'S THIRD SET OF INTERROGATORIES Governor George Deukmejian hereby responds to the third set of interrogatories propounded to him by applicant Pacific Gas and Electric Company.
INTERROGATORY NO. 1:
Identify each and every person you intend to or may call as a witness during these proceedings. ,
As to each such witness, state:
(a) Name, occupation, occupational address and telephone number.
(b) Whether the witness will render expert testimony.
(c) If the witness will render expert testimony, please list each specific subject matter about which the witness will be expected to testify.
(d) If the witness will be called to give expert testimony, please list the specific qualifications of the witness that you contend would qualify the witness to give 1*
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, A opinion testimony on each specific subject matter about which the witness will testify. -
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(e) List each and every professional article, book, or the like, if any, the witness has a khored or co-authored concerning each specific subject matteriset focth in your answer to 1(c) .
(f) Identify each and every document the witness will rely on to reach any opinion testimony and specifically corollate each such document (by page and paragraph number) to each specific subject matter on which the witness will render an opinion.
(g) As to each specific subject matter identified in your answer to 1(c), identify by docket number and case name each Nuclear Regulatory Commission licensing proceeding where the witness has previously given expert testimony concerning each specific subject matter.
(h) As to each proceeding iden tified in your answer to 1(g), please state:
(i) The date(s) the expert testimony was given.
(ii) Whether you have a copy of the testimony given.
(iii) Whether you have a copy of the transcript covering any or all of the witness' examination and/or cross-examination for each such proceeding.
(iv) Whether you have a copy of any notes which the witness made in preparation for , or utilized during, the w i tnes s ' examination or cross-examination in each such proceeding.
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(i) As to e ach specific subj ect matter identified in your answer to 1(c), identify by docket number and court name each legal proceeding where the witness has previously g'iven expert testimony concerning each specific subject matter.
(j) As to each proceeding identified in your answer to 1(i), please state:
(i) The date(s) the expert testimor.y was given.
(ii) Whether you have a copy of the transcript covering any or all of the witness' examination and/or cross-examination for each such proceeding.
(iii) Whether you have a copy of any notes which the witness made in preparation for, or utilized during, the witness' examination or cross-examination in each such pr oceeding .
(k) As to each specific subject matter identified in your answer to 1(c), identify committees and organizations where the witness has previously given testimony concerning e ach specific subj ect matter.
(1) As to each committee or organization identified in 1(k), please state:
(i) The da te(s) the expert testimony was given.
(ii) Whether you have a copy of the testimony given.
(iii) Whether you have a copy of the transcript covering any or all of the witness' examination and/or cross-examination for each such proceeding.
(iv) Whether you have a copy of any notes which the witness made in preparation for , or utilized during, the 3.
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O witness' examination and/or cross-examination in each such proceeding.
ANSWER TO INTERROCATORY NO. 1:
The only expert witness that the Governor presently intends to call is Jose M. Roesset. Dr. Roesset's qualifications are given in the attacned Exhibit.
(a) 3506 Duval Road, Austin, TX 7 8759; (512)835-0257.
(b) Yes.
(c) Struc tural engineering.
(d) See Exhibit.
(e) See Exhibit.
(f) Not presently determined.
(g) None.
(h) Not applicable.
(i) The only testimony Dr. Roesset has offered was given before the Nuclear Regulatory Commission in the proceedings on suspension of the Diablo Canyon low-power license.
(j) (1) September 1981; November 1981.
(ii) Yes.
(iii) No.
(k) Dr. Roesset has never given swor n " testimony" to any such committee or organization. To the extent that he has spoken to such organizations, no record is known to exist of the numerous instances of such professional contacts.
(1) Not applicable.
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INTERROGATORY NO. 2:
Please set forth with particularity each and every exhibit you intend to mark for identification at the reopened hearings on design quality assurance.
_ ANSWER TO INTERROGATORY NO. 2:
The Governor has not yet made a final determination as to the exhibits he may wish marked for identification at the reopened hearing on design quality assurance. A number of such potential documents, and portions thereof, are identified in the the Governor 's response to the " Licensee's Second Set of Interrogatories to the Governor." Pursuant to the Atomic Safety and Licensing Appeal Board's instructions at the August 23 and 24,1983, pre-hearing conference, the Governor anticipates providing a proposed exhibit list on the date established by the board.
INTERROGATORY NO. 3:
List specifically, including page and section number, each and every license commitment set forth in the Diablo Canyon FSAR which you allege has not been complied with.
ANSWER TO INTERROGATORY NO. 3:
The Governor 's review of the compliance of Diablo Canyon Units 1 and 2 with the FSAR and other license criteria is not yet complete. The results of the Governor 's review to date are summarized in the Governor's response to the 146 interrogator ies propounded in the " Licensee's Second Set of Interrogatories to the Governor." That answer is current as of S.
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the date of Tthis filing and will be supplemented as provided by 10 C.F.R. 5-2.740 (e).
INTERROGATORY NO. 4:
For ;each license commitment iden tified in your response to the preceding interrogatory, state in detail each and. every fact upon which you base your allegation that the license commitment has not been met.
ANSWER TO INTERROGATORY NO. 4:
The Governor's review of the compliance of Diablo Canyon Units 1 and 2 with the FSAR and other license criteria is not yet complete. The results of the Governor's review to date are summarized in the Governor 's response to the 146 interrogatories propounded in the " Licensee's Second Set of Interrogator ies to the Governor ." That answer is current as of the date of this filing and will be supplemented as provided by 10 C.F.R..S 2.740 (e).
INTERROGATORY NO. 5:
Specifically iden tify each and every document which you claim supports each f act set forth in your response to the preceding interrogatory and cor relate each such document (by page and paragraph number) with e ach such f act.
ANSWER TO INTERROGATORY NO. 5:
The G,overnor's review of the compliance of Diablo Canyon Units 1 and 2 with the FSAR and other license criteria is not yet complete. The results of the Governor's review to date are summarized in the Governor's response to the 146 interrogatories propounded in the " Licensee's Second Set of l
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Interrogatories to the Governor." That answer is current as bf the date of this filing and will be supplemented:as provided by ,
10 C.F.R..$ 2.740 (e). , -
DATED: August 31, 1983 JOIM K. VAN DE KAMP, Attorney General of - the S tate of Calif ornia ANDREA SilCRIDMI ORDIN, Chief '
Assistant Attorney General MICHAFL J. STRUMWhSSER, : Special Counsel to the Attorney General SUSAN L. DURBIN, PET 1tR H. ISUFMAN, Deputy Attor neys General -
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By b
- SUSAN L. DURBIN Attorneys for Governor George DeukmejiaA 3580 Wilshire Boulevard Suite 800 Los Angeles, Calif ornia 90010 .
(213) 736-2105 s
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EXHIBIT " A" l
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%n BIOGRAPHY Jose M. Roesset fE.
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Education 5- y{ ? E f T Escuela Especial de Ingenieros de Caminos - Madrid Spain 7 .
- id Civil Engineer w l1959- _
Massachusetts Institute of Technology,Sc. D.
1964 * .
Professional Employment ~
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Assistant Engineer, Agroman Empresa Constructura, Madrid 1954-1959. I Civil Engineer, Agroman Empresa Construction, Madrid 1959-1961 ::
Research Assistant, M.I.T. 1962-1963 Teaching Assistant, M.I.T. 1963-1964 Asisstant Professor, M.I.T., Dept. of Civil Engineering 1964-1969 Visiting Profecsor, University of Chile ]
1966-1969 Associate Professor, M.I.T., Dept. of Civil Engineering 1969-1975 Professor of Civil Engineering, M.I.T. 1975-1978 Professor of Civil Engineering, University of Texas 1978 to date _
M Professional Societies American Society of Civil Engineers S American Concrete Institute Colegio de Ingenieros de Caminos, Calales Y Puertos Publications
" Bridge Design System," with C. A. Cornell and J. F. Brotchie, M.I.T. Dept. of Civil Engineering Research Report R65-26, Septemver, 1965.
t "Fundamentos de Programacion y Use de Computadores," (Basic Programming and Use of Computers), published by University of Chile, 1966 (in Spanish)
"Methodos Numericos de Analisis Estructural" (Numerical Methods in Structural-Analysis) published by the Univeristy of Chile, 1966 (in Spanish)
"Analisis de Muros y Facadas Mediante Elementos Finotos," paper presented to Pan American Symposium, Caracas, 1967 (in Spanish) with T. Cuendalmann, R. Luft, and M. Sarrazin.
"Fundamentos del problema de optimazation del Diseno Estructural," Materiales, Maquinaria Y Metodos para la Construccion, No. 41, 1967 (in Spanish)
"ICWA-STRUDL I - Student Manual," M.I.T. Civil Engineering Report R68-71, September, 1968.
"The Use of ICES-STRUDL I in Design Courses," M.I.T. Civil Engineering Report R68-72, September, 1968.
" Theoretical Background for Amplification Studies," with R. W. Whitman, M.I.T.
Civil Engineering Report R69-15, March, 1969.
"Hysteretic Damping in Inelastic One-Degree-of-Fredeom Systems," with H. Kamil, M.I.T. Civil Engineering Report R69-52, August, 1969. ;
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" Nonlinear Dynamic Response and Ductility Requirements of Building Structures Subjected to Esrthquakes," by S. A. Anagnostopoulos (J.M. Roesset and J. M.
Biggs, supervisors) M.I.T. Civil Engineering Report R72-54, September, 1972
" Accuracy of Modal Superposition for One-Dimensional Soil Amplification Analysis."
with R. V. Whitman and L. Ayestaran. Paper presented at the Conference on Microzonation for Safer Construction Research and Application, Seattle, Wash-ington, October, 1972
" Ductility Requirements for Some Nonlinear Systems Subjected to Earthquakes,"
with S. A. Anagnostopoulos. Paper presented at the Fifth World Conference on Earthquake Engineering, Rome, June 1973
" Nonlinear Dynamic Analysis of Buildings with Torsional Effects," with S. A.
Anagnostopoulos and J. M. Biggs, Paper presented at the Fifth World Conference on Earthquake Engineering, Rome, June 1973 "A Comparison of Linear and Exact Nonlinear Analyses of Soil Amplification,"
with I. V. Constantopoulos and J. T. Christian. Paper presented at the Fifth World Conference on Earthquake Engineering, Rome, June 1973
" Planning and Cost Evaluation Program for Comparing Preliminary Design Schemes for Highrise Apartments," by T. G. Harmon (R.J. Hansen and J. M. Roesset, supervisors), M.I.T. Report R73-39, September, 1973
" Amplification Studies for a Nonlinear Husteretic Soil Model," by I. V.
Constantopoulos (J.T. Christian and J.M. Roesset, supervisors) M.I.T. Report R73-46, September, 1973
" Dynamic Response of Structures in Layered Soils,: by V. Chang-Liang (J.M.
Roesset and G. Waas, supervisors), M.I.T. Report R74-10
" Forced Vibrations of Circular Foundations on Layered Media," by E. Kausel (J.M. Roesset and G. Waas, supervisors), M.I.T. Report R74-11. Januarv. 1974
" Nonlinear Dynamic Response of Reinforced Concrete Frames," By Kenneth Mark (J . M. Re es se t , supervisor), M.I.T. Report R76-38, August 1976
" Inelastic Dynamic Analysis of Building Frames,"by Tarek Aziz( J.M. Roesset, supervisor) M.I.T. Report R76-37, August, 1976 "On the Simple Use of Models in Nonlinear Dynamic Analysis " by Javior Pique (J.M. Roesset, supervisor) M.I.T. Report R76-43, September, 1976 "Effect of Ductility on Response Spectra for Elasto-Plastic Systems," by Samir Schayer (J.M. Roesset, supervisor) M.I.T. Report R76-42, September 1976
" Dynamic Analysis of Fcotings on Layered Media," with E. Kausel and G. Waas, Proceedings ASCE, EM5, October, 1975 i
" Dynamic Stiffness of Circular Foundations," with E. Kausel, Journal of the Engineering Mechani.cs Division, ASCE, December, 1975
" Dynamic Soil Structure Interaction," with E. Kausel, Numerical Methods in Geomechanics, ASCE, Blacksburg, Virginia, June 1976.
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"The Use of Amplification Functions to Derive Response Spectra, Including the Effect of Local Soil Conditions," with M. Sarrazin and E. Vanmarcke, M.I.T.
Civil Engineering Report, R69-48, July, 1969.
" Analysis of Building Frames for Natural Frequencies and Natural Mode Shapes,"
with R.'LaTona, M.I.T. Civil Engineering Report R69-59, August, 1969.
"A Consistent Set of Finite Elements for Continua and Linear Members," by Rene W. Luft (J.J. Connor and J. M. Roseest, supervisors). M.I.T. Civil Engineer-ing Report R69-51, August , 1969 "Effect of the Angle of Incidence on the Amplification of SH Waves," Quarterly Progress Report of the Inter-American Program, R69-73.
' Soil Amplification of SV and P Waves," with Thomas J. Jones, M.I.T. Civil Engineering Report R70-3, January,1970.
" Influence on Damping on Response Spectra," with Freedy Garcia, M.I.T. Civil Engineering Report R70-4, January, 1970
" Fundamentals of Soil Amplification," page 183, Seismic Design for Nuclear Power Plants, M.I.T. Press, Cambridge, Mass., 1970
" Seismic Analysis of Equipment Mounted om a Massive Structure," page 319, Seismic Design for Nuclear Power Plants, M.I.T. Press, Cambridge, Mass., 1970
" Statistical Properties of Strong .?arthquakes," with Edmund Sixsmith, M.I.T.
Civil Engineering Report R70-7, January 1970
" Nonlinear Analysis of Building Frames for Earthquake Loading," by R. W. Latona (J.M. Roesset, supervisor), M.I.T. Civil Engineering Report R70-59, September, 1970
" Automatic Generation of Finite Element Matrices," with R. W. Luft and J. J.
Connor; Paper presented at the Fifth Conference on Electronic Comuptation, Purdue, September,1970 Journal of the Structural Division, ASCE, Bol. 97, January, 1971.
" Soil Properties and the One- Dimensional Theory of Earthquake Amplification,"
with R. Dobry and R. V. Whitman, M.I.T. Civil Engineering Report R71-18, May 1971 "The Conception and Design of the Structural System for the Standard 011 of Indiana Building - A Collection of Three Papers," Co-author of one of the papers)
, M.I.T. Civil Engineering Report R72-3, January, 1972
" Risk Analysis and Decision Models in the Planning of Housing Projects," by J.
A. Machado (J.M. Roesset, supervisor), M.I.T. Civil Engineering Report R72-44, June, 1972
" Dynamic Soil Structure Interaction,"with M. A. Sarrazin and R. V. Whitman, Journal of the Structural Division, ASCE. July, 1972.
" Modal Analysis for Structures with Foundation Interaction," with R. V. Whitman and R. Dobry, Paper presented at the Cleveland Convention of ASCE, April, 1972 4
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" Dynamic Stiffness of. Piles," with G. Blancy and E. Kausel, Numerical
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Methods in Geomechanics, ASCE Blacksburg, Virginia, June 1976
" Forced. Vibrations of Strip Footings in Layered Soils," with G. Gazaetas, Proceedings, National. Structural Engineering Conference, ASCE, Madison, Wisconsin, August 1976
" Dynamic Stiffness of Embedded Foundations," with F. Elasbee and E. Kausel, Proceedings, Second National Engineering Mechanics Confernece, ASCE, North Car 611na, May 1977.
" Nonlinear BeLavior in Soil Structure Interaction," with E. Kausel and J. T.
Christian, Journal of the Geotechnical Division, ASCE, November 1976 "Semianalytic Hyperelement for Layered Strata," Journal of the Engineering Mechanics Division, ASCE, Aug. 1977. with E. Kausel
" Transmitting Boundaries: A Comparison," International Journal for Numerical and Analytican Methods in Geomechanics, Vol. 1, 1977 with M. M. Ettouney "The Effect of Non-linear Inelastic Connection Behavior of Precast Panelized Shear Walls," with J. B. Becker and C. Llorente, Proceedings, ACI Symposium on Mathematical Modelling of Reinforced Concrete Structures, 1978 "The Seismic Response of Precast Concrete Panel Buildings," with J. M.
Becker, C. Llorente and K. Lanham, Proceedines 6th European Conference on Earthquake Engineering, Dubrovnick, Yugoslavia, Sept. 1978 "Effect on Inplane Slab Flexibility on the Dynamic Response of Shear Buildings,"
Proceedings ACI Symposium om Mathematical Modelling of Reinforced Concrete Structures, 1978.
" Plane Strain Soil-Structure Interaction for Seismic Response," with G. Gazetas, Proceedings 6th Symposium on Earthquake Engineering, Roorkee, India, Oct. 1978
" Nonlinear Effects in Soil Structure Interaction,"with J. Scaletti, Proceedines 3rd International Conference on Numerical Methods in Geomechanics, Aachen, Germany, April 1979.
" Dynamic Stiffness of Piles," with D. Angelides, Proceedings International Conference on Numerical Methods in Offshore Piling, London. England, May 1979
" Soil Structure Effects in Nuclear Power Plants," Proceedings 6th PanAmerican Symposium on Structures, Cordoba, Argentina, July 1979.
" Boundary Matrices for Semi Infinite Problems," Proceedings 3rd Engineering Mechanics Specialty Conference, ASCE, Austin, Texas, Sept. 1979
" Vertical Vibrations of Machine Foundations," Journal of the Geotechnical Engineering Division, ASCE, Dec. 1979 with G. Gazetas, pp. 1435=1454.
" Computer Models for Soil Structure Interaction Analysis," Journal of the American Society of Mechanical Engineers, C2, PVP-130, 1980.
! " Boundary Matrices for Seim-Infinite Problems," Proceedings, Engineering Mechanics Division Specialty Conference, The University of Texas at Austin, Sept. 17-19, 1979, pp. 384-387.
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, "The Use of Simple hodels in Soil Strheture Interaction," _ Proceedings , Specialty Conference on Civil Engineering and Nublear Power, Knoxville, Tennessee, Sept. 15-17, 1980.
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- .i ~, _L "Stif fness and Damping Coefficients of . Foundations,',' Proceedings._ American
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Society of Civil Engineers Annual Meetingf Hollywood, Florida, October 26-30, 1980 d-
" Computer Models for Soil Structure Interaction," Proceedings, Annual Meeting, American.Sociary of Mechanical Engineers, San Francisco, Dalifornia, January 21-23, 1981. n (with D. Angelides) " Nonlinear Lateral Dynamic Stiffness of Piles," Journal of the Geotechnical Division, American Society of Civil Engineers, Vol. 107, GT 11, November 1981, pp. 1443-1460. .
" Stiffness Matrix Approach for Layered Soils, " Proceedings of 7th World
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Conference on Earthquake Engineering, Istalbul, Turkey, September 8-13, 1980
" Modal Analysis of Nonlinear Systems," Proceedings, 7th World Conference on Earthquake Engineering, Istanbul, Turkey, September 8-13, 1980.
(with R. Dobry, E. Vicente and M. O'Rourke) " Horizontal Stif fness and Damping of Single Piles," Journal of the Geotechnical Division, American Society of Civil Engineers, Vol.108, GT 3, March 1932, pp. 439-459.
(with E. Kausel) " Stiffness Matrices for Layered Soils," Bulletin of the Seismological Society of America, Vol. 71, No. 6, 1981, pp. 1743-1761 (with E. Kausel and J.L. Tassoulas) " Consistent Boundaries for Semi-Infinite Problems," Computational Methods for Infinite Domain Media-Structure Interaction, American Society of Mechanical Engineers, Vol. 46, 1981, pp. 140-166.
" Soil Effects in the Seismic Response of Structures," in Spanish, Ingenieria Sismica, Vol. 1, 1981, pp. 41-75.
"Recent Advances in the Use of Computers in Civil Engineering," Proceedings, Symposium on the Use of Computers in Civil Engineering, Santander, Spain, August 15-22, 1982.
" Solution of Nonlinear Problems in Civil Engineering," Proceedings, Sumposium on the Use of Computers in Civil Engineering, Santander, Spain, August 15-22, 1982.
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UNITED SMTES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-32 3 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
CERTIFICATION I, Susan L. Durbin, hereby certify:
- 1. I am one of the attorneys for Governor George Deukmejian in the above entitled matter and, as such, am authorized to execute this certification.
- 2. I have read the f oregoing Governor Deukmejian's Answers to Applicant's Third Set of Interrogatories and know the contents thereof.
- 3. I am informed and believe said answers to be true and correct.
I ca:tify under penalty of perjury that the foregoing is true and correct.
Executed at Los Angeles, California, on August 31, 1983.
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SUSAN L. DURB IN l
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